Date: September 23, 2013

Issue: Accounting and Auditing

To: Board of Governors of the Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency

Filing TypeRegulatory

Description:  The CCMC is concerned that the proposed leverage ratio rules are premature. The Bank for International Settlements (“BIS”) has issued for comment a discussion paper on The Regulatory Framework: Balancing Risk Sensitivity, Simplicity and Comparability (“Basel III capital simplification paper”) in an effort to reduce the complexity and opaqueness of the Basel III capital agreements (Basel III”). Furthermore, the Federal Reserve has not yet completed the final promulgation of the rules implementing section 165 of the Dodd Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). The proposed leverage ratios are also creating a divergence from international standards. The Chamber also wishes to express concerns that the proposed leverage ratio rules may adversely impact the ability of businesses to attractcapital harming their ability to grow and create jobs

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